Early hearing of an appeal seeking revocation of GST registration cancellation was granted because the application met Rule 29 requirements and established that cancellation prevented continuation of business. The absence of any objection from the respondent supported priority listing. The appeal was therefore listed for priority hearing, enabling expedited consideration of registration revocation.

Rules 10, 12, 13 and 29 of the Goods and Services Tax Appellate Tribunal (Procedure) Rules, 2025 preserve inherent procedural powers, allow urgent listing, permit exemption from procedural requirements on sufficient cause, and recognise early-hearing applications. Continued inability to conduct business following cancellation of registration may constitute sufficient cause for urgent consideration. Procedural requirements should facilitate substantial justice rather than prevent timely appellate consideration. Any exemption from ordinary Registry scrutiny is limited to urgent listing and does not waive statutory conditions or determine the appeal's maintainability or merits.

Monetary-limit instructions under the Uttar Pradesh GST Act regulate departmental GST appeals, including appeals before GSTAT. Where only penalty is disputed, the disputed penalty determines whether the appeal meets the applicable threshold. Commissioner authorisation for an appeal does not independently exempt the Revenue from the litigation policy. A below-threshold appeal requires the Revenue to specifically plead and establish a recognised exception, including a reasoned, case-specific exercise of any residual power by the Commissioner. Without such an exception or recorded opinion, the departmental appeal is not maintainable.

Penalty for alleged diversion of goods under Section 129(3) requires an established contravention in the actual movement of goods. The department must displace the tax invoice and e-way bill with reliable evidence of diversion, unloading, or receipt by an undeclared recipient. Route deviation, a vehicle's presence near another factory, and an uncorroborated driver statement do not by themselves prove deliberate contravention. Reliance on undisclosed GPS-camera material also denies an effective opportunity to contest adverse evidence and breaches principles of natural justice. Without reliable proof, the factual basis for detention and penalty fails, making the penalty unsustainable.

Pre-show-cause audit closure under the CGST Act is an administrative step under the audit power and does not constitute quasi-judicial adjudication or prevent a proper officer from issuing notice for unpaid or short-paid tax. Ghamellas/Tasla, expressly named under Tariff Item 73239410, are classified there rather than as exempt agricultural hand tools: the specific description prevails under Rule 3(a), and legacy excise treatment does not govern GST classification. The January 2018 amendments are clarificatory rather than creating a new tax liability. Deliberately changing invoice descriptions for goods with unchanged characteristics constitutes misstatement and suppression, supporting an equivalent penalty; tax, interest and penalty remain enforceable.

Rule 138 requires an e-way bill for movement of goods above the prescribed consignment value, including internal stock transfers undertaken otherwise than by way of supply. A delivery challan under Rule 55 does not replace that requirement, and distance-based relaxations do not generally exempt e-way bill generation. However, transfer of tax-paid goods between a taxpayer's own godown and showroom, without consideration or another person, is not a taxable supply and creates no tax liability. A procedural e-way bill lapse cannot sustain a Section 129 penalty where no tax is payable and the facts do not establish deliberate tax evasion or clandestine removal.

Section 109(5) of the CGST Act permits specified classes of cases to be assigned exclusively to the Principal Bench. Appeals pending before two or more State Benches that raise an identical question of law, and for which the President has recorded satisfaction, must be heard by the Principal Bench under the notified class. Those appeals are outside State Bench jurisdiction. The identified common issue concerns eligibility for input tax credit in relation to telecom towers.

Input tax credit requires a valid invoice and proof of actual receipt of goods. Tax invoices, e-way bills, consignment notes, verifiable banking payments and undisputed consumption of inputs in manufacturing substantiate a purchaser's bona fides. A supplier's subsequent non-existence or retrospective registration cancellation does not, by itself, negate such evidence or justify credit reversal. Fraud-based penalty requires proof of fraud, wilful misstatement, suppression or collusion by the purchaser. Where reliable contemporaneous records establish purchase, transport, payment and consumption, and no material proves the purchaser's knowledge of or participation in supplier fraud, penalty and consequential tax and interest demands are unsustainable.

A prima facie bona fide explanation for delay supported admission of the GST appeal for regular hearing. Payment of 20% of the stipulated pre-deposit triggered the statutory deemed stay of recovery proceedings for the unpaid balance while the appeal remains pending and has not been dismissed. The respondents were required to comply with the recovery stay, while the merits of the underlying demand remain undecided.

Writ jurisdiction over pending inspection and search proceedings was not exercised before issuance of a show-cause notice or final liability determination. Disputes over independent witnesses, the panchnama, and the voluntariness of tax payment required assessment of contemporaneous material by the competent authority. The writ petition was dismissed at that preliminary stage without deciding the merits, and all contentions remained open in statutory adjudication.

Service of a seizure order under Rule 139(2) is satisfied where Form GST INS-02 identifies the seized articles and bears the affected person's signature acknowledging physical receipt. Disputed factual claims about preparation or communication of the seizure order generally cannot be resolved in writ jurisdiction solely on affidavits. Accordingly, acknowledged physical service of Form GST INS-02 prevents search and seizure proceedings from being invalidated on an allegation of non-service.

Input tax credit eligibility under Section 155 remains the claimant's burden to prove, even where seized records are unavailable. The relevance of unavailable records, resulting prejudice, and supplied or reconstructed material requires evidentiary assessment in the statutory appeal. Challenges concerning tax demand, interest, penalties, documentary evidence and input tax credit are to proceed through the appellate remedy under Section 107 rather than the writ route. Duplicate GST DRC-07 demand summaries generated by a portal glitch require rectification so that they match the demand confirmed in the adjudication order, including for statutory pre-deposit computation.

Ex parte GST adjudication was unsustainable where the order was uploaded solely under the portal's "Additional Notice and Orders" tab, without separate intimation or a personal hearing. The absence of a hearing raised a prima facie breach of natural justice. The order was quashed, requiring fresh adjudication after consideration of the taxpayer's reply, a personal hearing, and issuance of a reasoned order in accordance with law.

Section 127 transfer power is a machinery provision requiring a demonstrated, legitimate need for coordinated investigation. Alleged accommodation entries alone do not establish the necessary nexus; the Revenue must show structural links with the searched group, interlacing of funds, or interconnected business activities. An isolated banking transaction and an opaque factual basis indicate inadequate application of mind and disproportionate operational prejudice, rendering an inter-State jurisdictional transfer legally untenable.

Demand adjudication cannot disregard a reply uploaded in Form GST DRC-06 and proceed ex parte on the incorrect basis that no reply was filed. Consideration of the response, an effective personal hearing, and a reasoned decision are required; the demand must therefore undergo fresh adjudication. Negative blocking of the Electronic Credit Ledger under Rule 86A(1) cannot be used as a recovery mechanism for allegedly wrongful or ineligible input tax credit. Questions concerning return filing, registration cancellation, and ledger operability must be determined through the applicable statutory process.

Statutory appellate remedy before the GST Appellate Tribunal becomes available once the Tribunal is functional, even where a writ petition was instituted during its non-constitution. A petitioner may pursue the statutory appeal within the permitted period, with the time spent in writ proceedings considered by the Tribunal, subject to statutory compliance. This enables transition from writ proceedings to the ordinary appellate mechanism after the appellate forum becomes operational.

Section 83 permits provisional attachment only after qualifying proceedings commence, against property belonging to a taxable person or person covered by Section 122(1-A), where tangible material establishes that attachment is necessary to protect revenue. The power requires a live nexus between the material and necessity, and must satisfy proportionality; vague suspicions involving third-party money laundering or online gaming do not suffice. Attachment reasons cannot be supplemented by affidavit. Merchant settlement funds held in escrow under a trust are not the payment aggregator's attachable property. As no GST liability, identified transactions, evasion mechanism, or statutory coverage was established, the attachment and remaining debit-freeze restrictions were set aside.

Provisional attachment of a payment aggregator's current and regulated escrow accounts requires an opinion based on tangible material showing that attachment is necessary to protect revenue. Vague suspicion of GST evasion by unidentified third-party online gaming merchants, without identifying the aggregator's tax liability, relevant transactions, evasion method, or statutory status, does not satisfy that threshold. Escrow funds reserved for merchant settlements are held in trust and are not the aggregator's attachable property. The High Court treated the attachment orders and continuing debit freezes as illegal and quashed them.

Inter-State transfer of assessment jurisdiction for coordinated investigation requires a demonstrated structural nexus between the taxpayer and the searched group; an isolated transaction is insufficient. Alleged incriminating material must establish interlacing of funds or interconnected business activities, rather than an unfounded or non-transparent conclusion. Absent a legitimate necessity for coordinated investigation, transfer may be arbitrary, show non-application of mind, and breach natural justice. Assessment jurisdiction remained at Kolkata, while material gathered at New Delhi was to be sent to the Kolkata Assessing Officer for lawful inquiry, preserving the Revenue's ability to investigate there.

Service of a seizure order in Form GST INS-02 was satisfied where the order identified the seized articles and bore the petitioner's signatures acknowledging physical delivery. The High Court declined to resolve conflicting factual claims on affidavits in writ jurisdiction, rejected the non-service challenge to the search and seizure proceedings, and dismissed the writ petition. The merits of the statutory proceedings remained open before the competent authority.